ML20095D922

Forwards Revised Relief Request 52-VRR-1,Rev 1 for First 10-yr Interval Inservice Testing Program for Core Spray Injection Check Valve,Containment Isolation & Pressure Isolation Function

ML20095D922
Person / Time
Site:	Limerick
Issue date:	04/15/1992
From:	Beck G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9204270261
Download: ML20095D922 (3)

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10 CFR 50.55a(g)

PHILADELPHIA ELECTRIC COMPANY NUCLEAR GROUP HEADQUARTERS 1

955 65 CHESTERBROOK BLVD.

WAYNE t'A 19087 5691 (215) 640 6000 L

April 15, 1992 2

Docket Nos. 50-352 50-353 License Nos. NPF-39 NPF-85 U.S.

Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

Subject:

Limerick Generating Station, Units 1 and 2 Revised Relief Request for tne First Ten Year Interval

. Pump and Valve Inservice Testing Program Gentlemen:

Attached for your_ review and approval is a revision to Relief Request No. 52-VRR-1 for the Limerick Generating Station (LGS), Units 1 and-2, First Ten Year Interval Pump and Valve Inservice Testing (IST)

Program.

This revised relief request is being submitted in accordance with the requirements of 10 CFR 50.55a(g) (5) (iii) and 10 CFR 50.4.-

This relief requist.applian to.the Core Spray (CS) system and requests relief from-the American Society of Mechanical Engineers (ASME) Boiler and. Pressure Vessel (B&PV) Code Section XI, Subsection IWV requirements

concerning chcck valve exercise testing.

Relief Request No. 52-VRR-1 stipulates the method and frequency by which the CS system injection check valves will be tested.

.. Relief-Request No. 52-VRR-1-was included as part of_the LGS, Units 1 and'2, First Ten Year Interval IST Program originally submitted by L

our letter dated November 23, 1988.

By letter dated March 5, 1991, the NRC1 indicated,that_this Program, including relief requests, was acceptable for implementation provided that-the items identified in

' Appendix A of the Technical Evaluation Report (TER) portion of the Safety Evaluation Raport (SEP.) be addressed within the time frame specified in the SER.

This relief request is specifically addressed in the TER under Item 13 in Appendix A and in Section 3.]

1.1.

The TER L

states that relief from the ASME Code exercising frequency requirements

.may-be granted to verify the closure capability of the check valves =

during refueling outages: -however, relief should not be granted regarding the frequency (i.e., during refueling outages) for verifying the full-open position (i.e.,

forward exercise testing) of the check valves.. Therefore, as specified in the SEP, the NRC only granted partial relief and indicated that resolution of the denied relief g

should~be completed within six (6) months of receipt of the SER.

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Nuclear Regulatory Commission April 15, 1992 Document Control Desk

-Page 2 i

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i puring a telephone conversation with representatives of the NRC on August 27, 1991, we specifically discusned the details of this relief request.

We indicated that exercise testing.the check valves needed to be performed on a refueling autage frequenc7 due to the possibility of

" crud" intrusion and impact on reactor water chemistry if injection-testing through'the check ve41ve is performed quarterly or at cold shutdown.

No propose to perform forward exercise testing only dur.:ag refueling outages, as previously indicated.

The attached revision to Relief Request No. 52-VRR-1 provides the additional justification for perforning the CS system injection check valve full-open verification test during refueling outages only.

Testing these check valves during each plant shutdown as required by the ASME code is not practical for the reasons stated above and in L

the revised relief request.

. e would appreciate your expeditious W

review of-this revised relief-request so that we can limit testing to refueling outages; thereby, eliminating the' possibility of " crud" intrusion into the primary system during check valve testing.

If you have any questions or require additional information, please do not henitate to contact us.

Very truly yours,.

,/

G.

BecP r

Manager Licensing Section Attachment cc:

T.

T. Martin, Administrator, Region I, USNRC~(w/ -attachment)

T.

J.

Kenny, USNRC Senior Resident Inspector, LGS (w/ attachment) a...,.....,,....-.....,.

LGS 1 & 2, 3ST Program

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• Spec ML-005, Rey. 2 Appendix C Page 20 of 24 RELIEF REQUEST NO. 52-VRR-1, REVISION 1 l

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Systen:

Core Spray i

.Valvetsl:

HV-52-108 HV-52-208 Category:

A, C Function:

Cure spray injection check valves containment isolation and pressure isola tion function.

Testing Requirements:

Exercise in the forward and reverse direction.

r, asis for Relief:

The above valves are equipped with air ac tua tors that are designed to provide spring assistarce for valve closi.re only.

Therefore, flow exercising in the f orward direction can only be accomplished by injection into the vessel. Injection into the vessel using the core spray pump is not pessible because the core upray pump is not capable of overcoming reactor pressure during normal operation.

The HPCI wstem injects through this valve, however, this would require the injection of relatively cold water from the condensate storage tank into the reactor vessel via the HPCI punp.

The introduction of relatively colder water into the Reacter Coolant $ysten would resvlt in an excessive number of thermal ^ cycles to system-piping'and components.

Additionally, the introduction of colder water would increase reactivity due to the colder moderator temperature.

Therefore, as an alternate means of forward exercising, the valve will be manually full opened in accordance with T 9522(b).

Manually forward exercising -this valve at cold shutdown requires equalizing pressure across the valve.

Pressure equalizatie, across this valve would be accomplished tv injection oi' condensate into the vessel through a stagnated leg of the core spray sys+em. -Use of this injection path would introduce crud into the reactor vessel and could impact unit restart due to Technical Specification 3/4.4.4 chemistry

. requirements. A means of crud removal is not available because no vent ar drain path exists on this leg o f piping.

Crud removal fron this leg of piping can only be performed during refuel by flushing the core spray header into the reactor using station procedures.

The reactor water cleanup system would have to be placed into operation to reduce crud levels so the chemistry levels would be within acceptable ranges. Restart would be delayed by this cleanup process.

Additionally, manually forward exercising requires partial disassembly of the actuator, which if attenpted during cold shutdown, :ould result in a delayed plant start-up. Therefore, i

forward exercising will be accomplished at refueling and exercising in the reverse direction will be accomplished during Appendix J and Suetion XI leak rate testing.

-Alternate Testing:

Manually exerc5 sing in the forward direction will be performed at refueling. The force used to forward strcke these valves will no t exceed the criteria specified in 1HV-3522(b). Reverse flow closure will be verified at refueling by Appendix J and Section XI leak rate testing.

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